A recent letter to FASB suggested that APB 23 should be repealed. Although there is a clear lack of application guidance surrounding APB 23, repeal is not justified. Instead, FASB should address several practical uncertainties that have effectively allowed U.S. MNCs to make whatever APB 23 assumption best suits their needs.
Given that many U.S. MNCs have shifted substantial amounts of income to low-tax foreign jurisdictions and may need those foreign earnings back in the U.S. relatively soon, it is important for FASB to address these issues. If not, aggressive MNCs may continue to assert indefinite reinvestment when in fact they are likely to repatriate some portion of their low-taxed foreign earnings.
Law | Tax Law
Date of this Version
Harvey, J. Richard, "Should APB 23 Indefinite Reinvestment Be Repealed?" (2015). Working Paper Series. 191.